Fauquier Health

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Financial Assistance Policy

Financial Assistance Policy Number 831-105
Updated 7.2014

Purpose:

In carrying out its mission, Fauquier Hospital endeavors to collect a sufficient amount of money to maintain long-term financial stability and to provide the highest quality of care to the community it serves. Financial Assistance policies have been created to facilitate access to care based on county of residence, need and ability to pay. Fauquier Hospital strives to ensure that the financial capacity of people who need health care services does not prevent them from seeking or receiving care. Fauquier Hospital will provide, without discrimination, care of emergency medical conditions to individuals regardless of their eligibility for financial assistance or for government assistance.

Persons Affected:
Fauquier Hospital

Policy:
Treatment Services for all emergency medical conditions will be provided without regard to ability to pay. Payment is due after the service is rendered. Elective service customers may be rescheduled upon the approval of their physician if payment arrangements are not made, including:

Requested deposit not made

Acceptable arrangements not on file

Previous delinquency without good cause

Responsibility

Charity is not considered to be a substitute for personal responsibility. Patients are expected to cooperate with Fauquier Hospital’s procedures for obtaining charity or other forms of payment or financial assistance, and to contribute to the cost of their care based on their individual ability to pay. Individuals with the financial capacity to purchase health insurance shall be encouraged to do so, as a means of assuring access to health care services, for their overall personal health, and for the protection of their individual assets. In order to manage its resources responsibility and to allow Fauquier Hospital to provide the appropriate level of assistance to the greatest number of persons in need, the Board of Directors establishes the following guidelines for the provision of patient charity. The patient, unless a minor or legally incompetent, is always responsible for payment of the account balance. Any individual signing the financial responsibility form will be liable for payment of the related account. Depending on the applicable Virginia statute, the spouse and parents will be responsible for medical bills of the other spouse or child. The amount of responsibility is the full balance of the account including any insured amount unless Fauquier Hospital is contractually prohibited from collecting such insured amount.

Assignment of Benefits Fauquier Hospital will file claim forms for all insurances that are assigned to the organization with adequate proof of coverage. The responsible party(s) may be required to assist in the follow-up process of the claim and may be required to make payment if the insurance payer has not resolved a clean claim within forty (40) days in accordance with Virginia Law.

Definitions

For the purpose of this policy, the terms below are defined as follows:

Charity Care:Healthcare services that have been or will be provided but are never expected to result in cash inflows. Charity care results from a provider's policy to provide healthcare services free or at a discount to individuals who meet the established criteria.Family:Using the Census Bureau definition, a group of two or more people who reside together and who are related by birth, marriage, or adoption. According to Internal Revenue Service rules, if the patient claims someone as a dependent on their income tax return, they may be considered a dependent for purposes of the provision of financial assistance.

Family Income: Family Income is determined using the Census Bureau definition, which uses the following income when computing federal poverty guidelines:

Noncash benefits (such as food stamps and housing subsidies) do not count;

Determined on a before-tax basis;

Excludes capital gains or losses; and

If a person lives with a family, includes the income of all family members (Non-relatives, such as housemates, do not count).

Financial assistance: shall mean medical necessary charity care and discounted care provided by Fauquier Hospital based upon a patient’s financial need, as determined in accordance with this policy.

Uninsured: the patient has no level of insurance or third party assistance to assist with meeting his/her payment obligations. Gross Charges: The total charges at the organization's full established rates for the provision of patient care services before deductions from revenue are applied.

Emergency medical conditions: Defined within the meaning of section 1867 of the Social Security Act (42 U.S.C. 1395dd).

Medically necessary: Services or items reasonable and necessary for the diagnosis or treatment of illness or injury, as determined pursuant to the prevailing standard of care.

Financial Assistance: Uncompensated (Charity) Care

Fauquier Hospital will endeavor to provide the maximum amount of charitable services to indigent patients free of charge, while minimizing bad debts and other write-offs. The amount of charitable services will depend on the degree of both public and private support. Charity Care budgets will be set in the following priority:

Life Saving Emergency

Urgent Emergency Care

Acute Inpatient and Outpatient Care

Outpatient Diagnostic Care

Home Care

Elective Surgery and Other Service Offerings Not Considered Urgent or Life Threatening

In administering the amount of Charity Care, Fauquier Hospital will pay primary attention to providing needed services to indigent Fauquier and Rappahannock County patients. Subject to budgetary limitations, the following patients shall be eligible for free, uncompensated but medically necessary patient care:

1. All patients who are residents of Fauquier or Rappahannock Counties and whoseannual household family income falls at or below two-hundred percent (200%) of the poverty level, as defined by Federal Poverty Guidelines; and 2. All patients who are non-residents of Fauquier or Rappahannock Counties and whose annual household income falls at or below one-hundred percent (100%) of the poverty level, as defined by the Federal Poverty Guidelines

Fauquier Hospital will assist the patient in applying for uncompensated care (charity) and any other funding sources that may be available for which they may qualify. Pre-screening for charity care eligibility may be conducted at pre-admission or point-of-service for all private-pay accounts that cannot meet the deposit requirements.

Financial Assistance: Self-Pay Discounts Discounts from the charged amount will be available based on annual household income as a percentage of the Federal Poverty Guidelines, as published annually, as well as the number of dependents in the household. Discounts will only be available for self-pay patients who do not have insurance. Self-pay balances (after insurance has paid) are exempt from these self-pay discounts.

Discounts will be provided to residents of Fauquier and Rappahannock counties who do not have health insurance, complete the application for assistance and meet the following criteria:

Self-pay patients will be granted a thirty-eight percent (38%) discount from total charges, which will be applied to their account at the time of initial billing.

Special requests for exceptions to the above policy may be made to the Director of Patient Accounts. Exceptions to this policy must be approved by the Chief Financial Officer.

Self-Pay Discount Not Applicable

Fauquier Hospital offers certain services that are not applicable to the self-pay discounting policy. These services currently include but are not limited to all complimentary medicine services and all non-contracted services located at the Life Center. Management reserves the right to exclude certain services from the self-pay discounting policy on a going forward basis.

Limitation on Charges to Those Receiving Financial Assistance

Fauquier Hospital will not assess charges for services for emergency medical conditions or other medically necessary care to those who are eligible for financial assistance under this policy that exceed the amounts generally billed to individuals who have insurance covering such care. Such charges shall be based on either the best, or an average of the three best, negotiated commercial rates, or Medicare rates.

Pre-admission Process

Patients that are pre-admitted will have the opportunity of financial counseling at the time of pre-admission testing or by phone before admission. Various options for payment will be discussed and arranged before the service date. Individuals displaying a need for financial assistance may be routed to a financial counselor for application to the most appropriate program(s). Deposits may be requested.

Accessibility of Financial Assistance Policy

It is the policy of Fauquier Hospital to widely publicize this policy within the community served by the hospital. The hospital will notify all patients of this policy upon admission to the hospital. Signs will be posted strategically throughout the hospital (including all outpatient, ancillary and emergency department registration booths), which indicate the availability of financial counseling. Key clinical staff, department managers and the medical staff offices will be provided with training opportunities regarding the hospital’s financial policy and how to appropriately direct patients to financial counseling. Notifications regarding this policy and summary information shall be provided in both English and Spanish, the primary languages spoken by the population serviced by Fauquier Hospital. The policy is published on the hospital’s web site.

Financial Counseling

Financial counselors will make every effort to personally visit uninsured patients upon their admission to determine Federal / State financial assistance. Additional outreach will be made by written and telephone communication to outpatients whose balance meet the minimum threshold. In addition, financial counseling services will be available to all patients Monday through Friday from 8:00am to 5:00pm. Financial counseling staff will assist patients and prospective patients in determining whether they qualify for financial assistance from the hospital or from outside sources. Financial counselors are fully trained on hospital financial policies. Periodic audits will be conducted to ensure financial counselors and other authorized hospital management and staff are appropriately administering discounts consistent with this policy.

Method by Which Patients may Apply for Financial Assistance

1. Financial need will be determined in accordance with procedures that involve an individual assessment of financial need; and may

Include an application process, in which the patient or the patient’s guarantor are required to cooperate and supply personal, financial and other information and documentation relevant to making a determination of financial need;

Include the use of external publically available data sources that provide information on a patient’s or a patient’s guarantor’s ability to pay (such as credit scoring);

Include reasonable efforts by Fauquier Hospital to explore appropriate alternative sources of payment and coverage from public and private payment programs, and to assist patients to apply for such programs;

Take into account the patient’s available assets, and all other financial resources available to the patient; and

Include a review of the patient’s outstanding accounts receivable for prior services rendered and the patient’s payment history.

2. It is preferred but not required that a request for charity and a determination of financial need occur prior to rendering of non-emergent medically necessary services. However, the determination may be done at any point in the collection cycle. The need for financial assistance shall be re-evaluated at each subsequent time of services if the last financial evaluation was completed more than a year prior, or at any time additional information relevant to the eligibility of the patient for charity becomes known.

3. Fauquier Hospital’s values of human dignity and stewardship shall be reflected in the application process, financial need determination and granting of charity. Requests for charity shall be processed promptly.
Presumptive Financial Assistance Eligibility
There are instances when a patient may appear eligible for charity care discounts, but there is no financial assistance form on file due to a lack of supporting documentation. Often there is adequate information provided by the patient or through other sources, which could provide sufficient evidence to provide the patient with charity care assistance. In the event there is insufficient evidence to support a patient’s eligibility for charity care, Fauquier Hospital may use outside agencies in estimating income amounts for the basis of determining charity care eligibility and potential discount amounts. Presumptive eligibility may be determined on the basis of individual life circumstances that may include:
1. State-funded prescription programs;
2. Homeless or received care from a homeless clinic;
3. Participation in Women, Infants and Children programs (WIC);
4. Food stamp eligibility;
5. Subsidized school lunch program eligibility;
6. Eligibility for other state or local assistance programs that are unfunded (e.g., Medicaid spend-down);
7. Low income/subsidized housing is provided as a valid address; and
8. Patient is deceased with no known estate.
Income Verification Requirements

In order to determine a patient’s eligibility for charity care and/or the self-pay discount, Fauquier Hospital will need to verify household income for the applicant. Charity care and discounts will not be applied until all applicable income documentation is received from the patient based upon forms required by the hospital. The following information may be required; 1. Most recent pay stub from employer (within one month from date of request) for all members of the household who are employed 2. W-2 or copy of Federal tax filing from most recent tax year for all members of the household 3. Valid phone numbers for all employers for all members of household who are employed 4. Child support documentation 5. Unemployment benefits verification for all members of household who are employed 6. Passive income from trust funds, real estate holdings and other income producing assets. To the extent non-reported income is discovered by the Hospital or later disclosed by the patient, previously applied discounts may be revoked by the Hospital.

The main criteria used in determining applicable discount levels will be annual household income as of the date services were rendered. However, real estate holdings, trusts, and other passive income will also be considered in determining eligibility for discounts. To the extent income levels reported by patients are not consistent with Federal tax filings, employers for all household members will be contacted. Additional information may be required on a case by case basis.

Contract Accounts

Patients with balances exceeding one hundred dollars ($100) may request the minimum payment requirement as communicated by the patient to the hospital. The patient must pay four percent (4%) of the total balance (the balance of all outstanding accounts combined) or twenty-five dollars ($25), whichever is greater. In circumstances where the patient is unable to pay the Director of Patient Accounts will have the authority to reduce the patient’s monthly payment to three percent (3%) of the total account(s) balance. In no circumstances should monthly payment amounts be less than three percent (3%) of the total balance unless approved by the Chief Financial Officer or Chief Executive Officer. No interest will be charged the patient, provided the patient continues to meet the minimum monthly payment requirements. If monthly payments are not made consistent with this policy, the account will age consistent with hospital bad debt policy.

Relationship to Collection Policies

Fauquier Hospital management shall develop policies and procedures for internal and external collection practices (including actions the hospital may take in the event of non-payment, including collections action and reporting to credit agencies) that take into account the extent to which the patient qualifies for charity care or discounted care; a patient’s good faith efforts to apply for governmental assistance programs or financial assistance from Fauquier Hospital, and a patient’s good faith effort to comply with his or her payment agreements with Fauquier Hospital. Fauquier Hospital will not impose extraordinary collections actions such as lawsuits, wage garnishments, arrests, body attachments, liens on residences, or other similar legal actions against any patient without first making reasonable efforts to determine whether that patient is eligible for financial assistance under this financial assistance policy. “Reasonable efforts” include notifications by the hospital of this financial assistance policy upon admission and in written and oral communications with the patient regarding the patient’s bill, including invoices and telephone calls before collection action or reporting to credit agencies is initiated.

Bad Debt

Once an account has been processed through the routine collection channels internally, it may be assigned to an attorney or collection agency for collection. Although the age will vary somewhat from account to account due to the various elements contained in the patient billing file, the average period of time for in-house follow-up is not less than one-hundred twenty (120) days. In accordance with State and Federal Law, Fauquier Hospital reserves the right to bill the customer for interest, late fees, finance fees, and collection costs as they apply.

Collection Agency Requirements

All contracted collection agencies will receive a copy of the hospital’s financial assistance policy and will be expected to follow the same guiding principles as the hospital’s policy. All collection agencies will be expected to treat Fauquier Hospital patients with courtesy, dignity and respect. Fauquier Hospital management will approve all routine collection agency correspondence (form letters and telephone scripts) utilized by collection agencies to collect debts from hospital patients. Once an account has been sent to the agency and remains unpaid for a 90 day period after initial transfer, the account will be reported to the Credit Bureau.

Delinquent Insurance Balance

Any insurance claim outstanding for more than ninety (90) days may become the responsibility of the patient (except where prohibited by contract). The patient may be requested to assist in the follow-up process prior to ninety (90) days. State laws governing clean claims processing managed care insurance payment timeliness will be strictly enforced, as will managed care contract terms regarding claim payment timeliness.

Third-Party Litigation

Fauquier Hospital will supply all documents needed as requested by the patient or his or her representative in pursing litigation against another party (i.e. automobile accident). Any outstanding balance regarding that account will be due in full following routine insurance filing. Should the account remain unpaid, it may be referred to an attorney or agency for legal representation

Defense Audits
Fauquier Hospital will provide space, equipment, and files for all third-party audits that are scheduled, present release, and show credentials. Audits must be conducted consistent with third party payer contracts and state law.

Payment Terms

Various options for payment are available to the patient; cash, check and credit card. Patients are required to select one of these options, apply for Medicaid/Charity care, establish a contract account, or be referred into the collection program. Exceptions must be approved by the Chief Financial Officer.

Overpayments and Refunds
Overpayment of account balances will be applied to outstanding balances for the same patient or guarantor (family). If there are no outstanding debts, the overpayment will be refunded to the appropriate party within a reasonable time frame.
Medicaid Eligibility

Fauquier Hospital will make every effort to determine if uninsured patients meet criteria for any State / Federal assistance. Patients are reminded that this process is a joint effort between themselves and the hospital and as such will require their cooperation in furnishing the requested financial and personal information. Financial Counselors will assist in completion of all applications and forward them to the appropriate agency upon completion. Patient’s accounts that have pending applications will be held without collection activity until efforts have been exhausted to obtain any available assistance.

Confidentiality
The staff of Fauquier Hospital will always treat all customers with respect and dignity. All records and information, including knowledge of a debt, will be held in strictest confidence.
Patient Pay Amounts

All patients with third-party insurance are expected to pay copayments in full at the time services are rendered. Emergency Department copayments may be required after services are rendered in accordance with the Emergency Medical Treatment and Active Labor Act (EMTALA). Coinsurance, deductibles and all other patient pay balances are due within ninety (90) days of payment by third-party insurance unless alternative arrangements are made by the patient consistent with the contract account policy.

Courtesy Adjustments

The Chief Executive Officer and the Chief Financial Officer or their designees have the right to adjust any outstanding patient bill. Documentation as to the nature of the adjustment will be reflected in the patient account history. Please refer to Policy Number 831-106 for more specific information regarding courtesy adjustments.

Employee Payroll Deductions
Payroll deductions are available to hospital employees and their immediate family members for outstanding account balances. In order to receive this benefit, the employee must be presently employed by Fauquier Health System.